Unfortunately I have only been able to get to reading the IRT report over the last couple of days. I have some personal comments to make, or they can be appended to the ALAC statement. I made my attribution flexible at the bottom (member of at-large or member of the proposed consumer constituency). May I ask whoever is heading up the ALAC comment to let me know if you want to include this? If not, I will send it myself to the public comment URL by end of business today. Thanks Beau Comment on Draft IRT Report Speaking as the organizer of the proposed consumer constituency to the GNSO under consideration for charter, I want to say I appreciate the IRT group’s inclusion of several issues of consumer concern in its draft report: * The need to minimize abusive and speculative registrations, seeking to temper the proliferation of cybersquatting, typosquatting, link farming and other Internet junk clutter. * Use of a global protective marks list to help limit consumer confusion in circumstances in which a consumer might be fooled into taking an action or making a purchase of fraudulent and possibly harmful goods and services. * Consideration of a uniform rapid suspension system. I also applaud the group’s understanding that certain behaviors of trademark violators go hand in hand with other bad behaviors. The most harmful of phishing frauds, for instance, hijack well-known trademarks as they seek to spoof and defraud consumers. However, I have some concerns as well. First, I think the IRT group was conceived inappropriately. One of its goals was to consumer protection. Several resources in the ICANN community exist to provide direct input from consumers and consumer groups. However, the IRT constructed itself in a closed manner, excluding participation from, at least, several individuals in the at-large. In this way, I think the IRT was constructed in a way that does not represent ICANN’s multi-stakeholder, consensus approach. Given how easy it would have been to include such consumer perspectives in the process, I think the IRT shot itself in the foot in terms of credibility. Unfortunately, the draft report reflects the group’s homogenous construction. Had consumer groups been invited to participate, we would have sought common ground and supported some of the IRT’s suggestions as having global application and reach toward consumer protection. Instead, the IRT report focuses primarily on creation of a discrete “clearinghouse” that seeks to address intellectual property community issues to the exclusion of others, while creating possibly yet another level of bureaucracy that may or may not obstruct the registration process. In addition, in respect to suggestion of uniform rapid suspension: Certainly there could be benefits to consumers, in light of limitations in the relatively antiquated UDRP process. But why should intellectual property interests be granted their own suspension mechanism? Why not a suspension system that takes into account other parts of the ICANN community? If the ICANN community is to consider an IP rights issues clearinghouse, and a new type of IP suspension system, then these should be implemented with the consideration and input of other members of the ICANN community. We as consumers, in fact, would not support creation and adoption of the clearinghouse, or the URS, unless they were opened to a broader group. Beau Brendler [Proposed] Consumer Constituency ALAC representative, At-Large ** This e-mail message is intended only for the designated recipient(s) named above. The information contained in this e-mail and any attachments may be confidential or legally privileged. If you are not the intended recipient, you may not review, retain, copy, redistribute or use this e-mail or any attachment for any purpose, or disclose all or any part of its contents. If you have received this e-mail in error, please immediately notify the sender by reply e-mail and permanently delete this e-mail and any attachments from your computer system.